1. Introduction

The protection and security of your personal data are important to us. The purpose of this privacy policy ("Policy") is to outline how we deal with personal data when you interact with us, including visiting this website www.glomopay.com ("Website"). This policy also tells you about your privacy rights.

Our Website is operated by Glomo Payments Software Private Limited ("Glomo Payments", "we" or"us"), who is a fiduciary of the personal data processed in connection with this Policy.

2. Types of Information Collected

Personal data, or personal information means any information or opinion about an identified individual or from which an individual can be reasonably identified. It does not include data about someone whose identity has been removed from such data (anonymized data).

We collect and hold personal information that is necessary for, or related to, one or more of our services or activities; or because it is required under a relevant law or regulation.

The types of personal information that we will collect from you will depend on the nature of your interaction with us. We may collect, use, store, and transfer different kinds of personal data about you as follows:

1. Contact data, including name, address, email address, and telephone number.

2. Employment data, including the company you work for and job title.

3. Transaction Data, including details about services you request from us.

4. Technical Data, including information about how you use our website, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.

5. Marketing and communications data, including your preferences in receiving marketing from us.

6. Data collected via our use of cookies and similar technologies.

7. Your CV and any other data you provide when you apply for a role with us.

From time to time, you may be able to deal with us anonymously or via a pseudonym. However, where we need to collect personal data, for example, by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. Collection

We collect personal information to provide our services and for our business operations. We describe the main types of personal information we collect and the main reasons why we collect that information below. We usually receive this personal data directly from you, either because you submit the information via the Website, or because we automatically collect it from you.

We may collect information that you give to us when you or your authorised representatives interact with us, for example, if you contact us regarding our services. We may also collect information from outside sources such as our business and commercial partners, credit reporting bodies, consultants, other customers and from publicly available sources (such as published content) and/or data providers.

We also collect personal information about individuals employed by our suppliers, contractors, dealers, agents, and corporate customers. When you apply for a job or contract with us, we may collect information about you to help us decide whether to offer you the job or contract. For example, we may collect information about how to contact you, your education or work history, or other information included in your CV or résumé. We may collect this information from you, or from any recruitment consultant, your previous employers, or other referees.

4. Purposes for processing your personal data

We may process any personal data you provide to us to enable us to deliver our services, to ensure our compliance with legal and regulatory requirements, including the following:

1. to enable us to verify your identity;

2. to enable us to verify, facilitate, respond to and/or process an enquiry or other request you make when you contact us, including for customer services support;

3. to manage your relationship with us;

4. for purposes related to the administration of services offered by us;

5. to notify you about changes to our services;

6. for researching, designing, and launching new services;

7. to better understand how you interact with our Website/App, including its functionality and features, and ensure that content is presented in the most effective manner;

8. for record-keeping purpose;

9. to respond to requests for information from public and governmental/regulatory authorities, statutory board, related companies and for audit, compliance, investigation and inspection purposes;

10. to enable us to respond to an enquiry or other request you make when you contact us via our Website/App;

11. to communicate with you via our marketing materials;

12. to assess your suitability for a role with us; or

13. to establish, exercise, or defend a legal claim.

5. Marketing

We may also use your personal data to send you marketing-related information (such as e-mail communications) where it is linked to the services we are providing to you or that you have made enquiries about. You may unsubscribe at any time by clicking on the "unsubscribe" link at the bottom of each marketing communication.

Please note that where you opt-out of receiving marketing communications, we may still send you certain communications relating to your use of our services, such as service announcements, notices about information on services, and administrative messages.

6. Cookies

We use cookies and similar technologies ("Cookies") on our Website to collect personal information.

7. Disclosing your personal information

Your personal information may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, for one or more of the purposes set out above:

1. our third-party service providers;

2. public and government/regulatory authorities, statutory boards, industry associations and/or agencies under applicable laws;

3. courts and other alternative dispute forums; and

4. our bank partners

Where we provide your personal information to any third-party service providers, they are required to keep your personal information confidential and secure and must only use your personal information as instructed by us.

8. Keeping your personal information secure

We will take all reasonable steps (including appropriate technical and organisational measures) to ensure your personal information is processed securely to protect the confidentiality, integrity, and availability of your personal information.

However, please be aware that the nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet and any transmission is at your own risk.

9. Storing your personal information

We maintain a log of all transactions undertaken by you for at least ten (10) years. We make this data available for scrutiny by the International Financial Services Centres Authority ("Authority") or any other agency as may be directed by the Authority.

Other than transaction data, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

10. Your Rights

You have the right to:

1. Request access the personal data we hold about you;

2. Request identities of all third parties with whom we may have shared your personal data along with a description of the data so shared;

3. Request we correct any inaccurate personal data we hold about you;

4. Withdraw your consent, where we have requested your consent to process your personal data;

5. Nominate any individual who will exercise these rights in the event of death or incapacity;

6. Seek redressal of grievance through our grievance redressal mechanism if you feel like we have not performed our obligations as per applicable laws or this privacy notice; and

7. Lodge a complaint with the Data Protection Board of India if you feel we have infringed your rights.

In certain circumstances, you may have the right to:

1. Request we delete any personal data we hold about you;

2. Restrict the processing of personal data we hold about you;

3. Object to the processing of personal data we hold about you; and/or

4. Receive personal data we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company.

11. Accuracy and requests for access and correction of personal information

When you submit your personal information to us, you should ensure the personal information is accurate and let us know promptly if the personal information changes so that we are not holding any inaccurate personal information about you.

We will take reasonable steps to ensure that the information we hold about you is relevant, accurate, up-to-date, and complete.

You can request that we provide you with access to information we hold about you or ask us to correct any personal information we hold about you that is out-of-date, incorrect, incomplete or misleading. You can contact us by submitting a request in writing to the address set out below. If we can, we will action on your request within a reasonable timeframe (usually within 30 days) following receipt of your request.

12. Complaints

You may contact us at any time if you have any questions or concerns about this Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to our Privacy Officer using the contact details set out below:

Juhilata Puntambekar
legal@glomopay.com

Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps that can be taken to resolve the complaint.

Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within a reasonable time, usually within thirty (30) days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

13. Changes to this Policy

Any changes to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

14. Contact Us

If you have any questions about the processing of personal data via this Website, please contact legal@glomopay.com. We will do our best to address any concerns you may have about our processing of your personal data.